Sedhom Law Group, PLLC
Last Modified: May 9, 2023
Information We Collect
We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked with a particular consumer, household, or device (“personal information”). Personal information does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
In particular, we have collected the following categories of personal information from consumers within the last 12 months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name,
Social Security number, driver’s license number, passport number, or
other similar identifiers.
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or
description, address, telephone number, passport number, driver’s
license or state identification card number, insurance policy number,
education, employment, employment history, bank account number, credit
card number, debit card number, or any other financial information,
medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin,
citizenship, religion or creed, marital status, medical condition,
physical or mental disability, sex (including gender, gender identity,
gender expression, pregnancy or childbirth and related medical
conditions), sexual orientation, veteran or military status, genetic
information (including familial genetic information).
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies.
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying
information, such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns, and sleep,
health, or exercise data.
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||NO|
|G. Geolocation data.||Physical location or movements.||NO|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||NO|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||NO|
|J. Non-public education information (per the Family Educational Rights and
Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
|Education records directly related to a student maintained by an educational
institution or party acting on its behalf, such as grades, transcripts,
class lists, student schedules, student identification codes, student
financial information, or student disciplinary records.
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological
trends, predispositions, behavior, attitudes, intelligence, abilities,
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that personal information to respond to your inquiry.
- To respond to law enforcement requests and as required by law, court order, or governmental regulation.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Website Users or consumers is among the assets transferred.
We won’t collect additional categories of personal information or use the personal information for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may share your personal information by disclosing it to a third party for business purposes. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the last 12 months, we have not disclosed personal information for business purposes.
We do not sell personal information.
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise them.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you or about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purposes for collecting or selling that personal information.
- If we sold or disclosed your personal information for a business purposes, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipients purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- The specific pieces of personal information we collected about you (also called a data portability request).
We do not provide a right to know or data portability disclosure for business-to-business personal information.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or a service provider to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated within the contact of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or to prosecute those responsible for such activities.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided by law.
- Comply with the California Electronic Communications Privacy Act.
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Right to Know or Delete
To exercise your right to know or delete, please email us at email@example.com or call 212-664-1600.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.
You may only submit a request to know twice within a 12-month period. Your request to know or delete my provide sufficient information that allows us to reasonably verify you are the person about whom we collected persona information or an authorized representative of that person. You must also describe your request with enough detail that we can properly understand, evaluate, and respond to it.
We can’t respond to your request or provide you personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your request within 10 business days. If you don’t receive confirmation within that timeframe, please email us at firstname.lastname@example.org.
We will try to substantially respond to a verifiable consumer request within 45 days of receipt. If we need more time (which could be up to an additional 45 days), we will inform you of the reason and the extension period.
Any disclosures will only cover the 12-month period preceding receipt of your request. The response will explain the reasons we cannot comply with the request (if applicable). For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another without hinderance.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or younger, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years old. To exercise the right to opt-out, you or your authorized representative may submit a request by emailing us at email@example.com. Once you make an opt-out request, we will wait at least 12 months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by emailing us at firstname.lastname@example.org.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- deny you services;
- charge you different prices or rates for services, including through granting discounts or other benefits, or imposing penalties;
- provide you a different level or quality of services; or
- suggest that you may receive a different price or rate for services or a different level or quality of services.
However, we may you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Changes to This Policy